2007 LPSIP Self Audit -Rev 1 Final
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2007 Annual LPSIP Self-Audit Report for Longhorn Partners Pipeline, L. P. May 20, 2008 Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008 Contents: 1.0 Introduction.............................................................................................................3 2.0 Self-Audit Purpose (LMP 3.2.13)............................................................................3 3.0 Program Goals (LMP 3.2).......................................................................................3 4.0 LPSIP Goals (LMP 3.1.5)4 5.0 Self-Audit Methodology ..........................................................................................5 6.0 Self-Audit Scope (LMP 3.5.12.3) ............................................................................6 7.0 LPSIP Commitment Review (LMP 3.0)...................................................................6 7.1 LPSIP Process Elements (LMP Sections 3.2.1, 3.4, and 3.5) ................................7 7.2 Data Gathering and Identification and Analysis of Pipeline System Threats (LMP 3.2.2) ......................................................................................................................9 7.3 Annual Third Party Damage Prevention Program Assessment (LMP 3.2.2.5) .....10 7.4 Integration of System-Wide Activities (LMP 3.2.3) ...............................................11 7.5 Integration of New ...
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2007 Annual LPSIP Self-Audit Report for Longhorn Partners Pipeline, L. P.
May 20, 2008
Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
Contents: 1.0 ................Introduction.....................................................................3........................ 2.0 ............................................................................3Self-Audit Purpose (LMP 3.2.13) 3.0 Program Goals (LMP 3.2).......................................................................................3 4.0 LPSIP Goals (LMP 3.1.5) .......................................................................................4 5.0 Self-Audit Methodology ..........................................................................................5 6.0 Self-Audit Scope (LMP 3.5.12.3) ............................................................................6 7.0 LPSIP Commitment Review (LMP 3.0)...................................................................6 7.1 ................................7LPSIP Process Elements (LMP Sections 3.2.1, 3.4, and 3.5) 7.2 Data Gathering and Identification and Analysis of Pipeline System Threats (LMP 3.2.2) ......................................................................................................................9 7.3 Annual Third Party Damage Prevention Program Assessment (LMP 3.2.2.5) .....10 7.4 Integration of System-Wide Activities (LMP 3.2.3) ...............................................11 7.5 Integration of New Technologies (LMP 3.2.5) ......................................................11 7.6 Root Cause .....................................12Analysis and Lessons Learned (LMP 3.2.6) 7.7 Industry Wide Experience (LMP 3.2.7) .................................................................13 7.8 ..........................................................................13Resource Allocation (LMP 3.2.8) 7.9 Workforce Development (LMP 3.2.9) ...................................................................14 7.10 Communication to Longhorn and Operations Management (LMP 3.2.10)............14 7.11 Longhorn’s Continuing Commitment (LMP 3.2.14)...............................................16 7.12 Operational Data Review......................................................................................16 8.0 .................................................................................................16Self-Audit Results 8.1 Process Elements ................................................................................................17 8.1.1 Corrosion Management Plan............................................................................................ 18 8.1.2 In-Line Inspection and Rehabilitation Program ................................................................ 19 8.1.3 Key Risk Areas Identification and Assessment ................................................................ 20 8.1.4 Damage Prevention Program........................................................................................... 21 8.1.5 Encroachment Procedures............................................................................................... 22 8.1.6 Incident Investigation Program......................................................................................... 23 8.1.7 Management of Change................................................................................................... 24 8.1.8 Depth of Cover Program .................................................................................................. 25 8.1.9 Fatigue Analysis and Monitoring Program ....................................................................... 25 8.1.10 Scenario Based Risk Mitigation Analysis ......................................................................... 26 8.1.11 Incorrect Operations Mitigation Program.......................................................................... 27 8.1.12 System Integrity Plan (LPSIP) Scorecarding and Performance Metrics Plan .................. 28 8.2 Five Core Areas to be Addressed ........................................................................28 8.2.1 Synopsis of the Most Important Integrity Issues Being Addressed .................................. 28 8.2.2 ................................................................. 29Important Results, Insights, Lessons Learned 8.2.3 .................................................................. 29Insights from New Technologies or Practices 8.2.4 Performance Measurement Results................................................................................. 29 8.2.4.1 General Program Performance Measures ....................................................................... 30 8.2.4.1.1 Incident Data................................................................................................... 31
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
8.2.4.1.2 Risk Awareness .............................................................................................. 32 8.2.4.1.3 Public Customer Service ................................................................................ 32 8.2.4.1.4 ...............................................................Operator Resources and Innovation 33 8.2.4.2 ............................................................................................. 33Specific Program Measures 8.2.4.2.1 .......................................................................... 33Corrosion Management Plan 8.2.4.2.2 Depth of Cover Program ................................................................................. 34 8.2.4.2.3 Damage Prevention Program ......................................................................... 34 8.2.5 New Programs, Initiatives, or Improvements.................................................................... 35 9.0 Recommendations ...............................................................................................35 10.0 usion...Concl.........................................................................................35................
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
Executive Summary In February through April 2008, Longhorn Partners Pipeline, L. P. (Longhorn) carried out the 2007 annual self-audit of the Longhorn Pipeline System Integrity Plan (LPSIP). The LPSIP is applicable to the Longhorn Partners Pipeline, which is operated by Magellan Pipeline Company, L. P. (Magellan). For the purposes of this report, the term Longhorn applies to Longhorn Partners Pipeline, L. P. and all the associated entities that are engaged to satisfy the requirements of the Longhorn Mitigation Plan (LMP). The primary purpose of the self-audit is to continuously improve the system integrity program. As part of the audit, the program is evaluated to determine its effectiveness, gauge performance, and make modifications as appropriate to improve the program. Longhorn framed the scope of the self-audit and prepared a reporting template to organize observations and findings. Det Norske Veritas (U. S. A.), Inc. (DNV) personnel were engaged to carry out the self-audit and provide an objective assessment of the results for the third year of operations of the Longhorn system. The LPSIP activities and program results for 2007 were reviewed. Further, the processes used to identify and assess risks, evaluate risk control options, review justification for resource allocation, and monitor performance were examined. This report specifically addresses the following five areas in the results section of this report, as required by LMP Section 3.5.12.3. 1. Synopsis of the most important integrity issues being addressed on the Longhorn Pipeline System and the status of activities and programs used to manage these risks. 2. Important insights, results, and lessons learned from the 2007 operating year. 3. Insights from any new integrity management processes or technologies, or innovative applications of existing technologies. 4. Performance measurement results. 5. New integrity management programs or activities that will be conducted or significant improvements to existing programs and activities resulting from the evaluation of the LPSIP. Summary of Observations Longhorn has experienced excellent results regarding illness, injury, property damage, and environmental protection. The Longhorn scorecards for 2007 indicated one (1) occupational injury report and one (1) DOT reportable release, in a Tier 1 area. Longhorn has achieved a high level of compliance for execution of the activities required by the LPSIP. Exception reports from the Compliance Management System and the Corrosion Management Plan database (CPDM) indicated no activities exceeding the established time-frames. Spot checking of paper records and field data supported the database exception reports. Several construction and upgrade projects commenced in 2007 with the objective to provide improved levels of safety and to meet operational targets. The self-audit team offers recommendations regarding the change management aspects of these activities. Now in the third year of operations, Longhorn has established processes and systems for executing the required activities. There is a high level of awareness of LMP requirements among
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
the workforce, and the activities are well integrated into the normal work planning for field employees. The self-audit team has made recommendations regarding continual improvement activities that would be directed at enhancing the effectiveness of LPSIP work.
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
1.0 Introduction Longhorn conducted the annual self-audit of the Longhorn Pipeline System Integrity Plan (LPSIP) in February through April of 2008. The LPSIP is applicable to the Longhorn Partners Pipeline, which is operated by Magellan Pipeline Company, L. P. (Magellan). For the purposes of this report, the term Longhorn applies to Longhorn Partners Pipeline, L. P. and all the associated entities who are engaged to satisfy the requirements of the Longhorn Mitigation Plan (LMP). 2.0 Self-Audit Purpose (LMP 3.2.13) The purpose of the self-audit is to assist Longhorn to continuously improve. This is achieved through evaluating the system integrity program to determine effectiveness, gauge performance, and make modifications as appropriate to improve the program. Longhorn conducted the self-audit utilizing the services of Mr. Karl Van Scyoc and Dr. Gary Kenney. Karl and Gary both participated in the 2006 Self Audit and Karl participated in the 2005 Self Audit as well. While Longhorn is fully cognizant of the regulatory requirements of the LMP, LPSIP, and applicable portions of Title 49 of the Code of Federal Regulations (CFR), this report is not intended as an attempt to audit the parameters of 49 CFR 195 or address regulatory compliance issues. The Office of Pipeline Safety (OPS) performs regulatory oversight for the Longhorn operations and performs inspections for the purposes of determining regulatory compliance. The results of the 2006 OPS inspections and other regulatory activities were reviewed and incorporated where applicable in this report. The results of the Self-Audit are intended to be shared with OPS and made available to the public. 3.0 Program Goals (LMP 3.2) The program goals for oversight and Longhorn system information sharing are stated in the LMP, as follows: • Enhance public safety and environmental protection by concentrating the deployment of Longhorn and OPS inspection resources to areas of greatest safety and environmental risk, and by addressing issues of mutual concern. • Provide OPS with an enhanced understanding of Longhorn’s entire system, including pipeline operation and maintenance programs. A more broad-based understanding of Longhorn’s integrity issues enables OPS to better consider and review with Longhorn the range of available integrity enhancements. The content of this report supports the LMP program goals by offering insights from the results of Longhorn’s 2007 year of operations. The report considers the effectiveness of resource deployment and provides information that promotes an enhanced understanding of the entire system by Longhorn’s stakeholders.
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
The LMP is comprised of three primary sections, as depicted in Figure 3-1.
Figure 3-1 LMP Contents The scope of the self-audit, as prescribed in the LMP, is intended to cover the LPSIP and the commitments made by Longhorn for implementing and carrying out the activities of the LPSIP. 4.0 LPSIP Goals (LMP 3.1.5) The audit team evaluated the LPSIP results from the 2007 year of operations for comparison with the goals identified in LMP Section 3.1.5. The stated goals of the LPSIP are that it be: Effective • To function as an integral part of, and value added contributor to, our ongoing pipeline operations, construction activities, and business development processes • To minimize accidents, and their consequences, on the Longhorn pipeline • To help guide the allocation of resources to minimize our operational risks • To identify all risks along the pipeline • To enhance long term safety • To educate and inform all stakeholders on identified risks • OPS, other governing and regulatory agencies, and additional LonghornTo meet the intent of commitments Efficient • To mitigate risk with the highest benefit to cost ratio Adaptable • To adapt to change and unique requests • To monitor, evaluate, and implement new technologies Continuous Improvement • To provide a method to confirm or improve the effectiveness, efficiency, and adaptability of the program by continuously measuring, evaluating, and upgrading the program.
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
The LMP self-audit commitment states that Longhorn is to perform an annual self-audit of its LPSIP, with the intention of ensuring that stated plan goals, objectives, and commitments are being met. Further, the self-audit process provides the framework for overall LPSIP feedback and continual improvement. (See LMP 3.5.12). The LPSIP activities and components are represented by Figure 4-1.
Figure 4-1 Longhorn LPSIP Activities and Components
5.0 Self-Audit Methodology In carrying out the 2007 annual self-audit, the audit team: Performed the following self-audit activities: • - Reviewed LPSIP processes and operational documents, data and activity results - Conducted face-to-face interviews of key personnel - Analyzed the data collected in support of performance metrics and LPSIP activities completed during the audit period - Evaluated the performance metrics and assessed the effectiveness of the LPSIP • Provided a written report of the self-audit results. • presentation of the self-audit results to key Longhorn management andDelivered a summary staff. The audit schedule provided the ability to review a representative sample of the employees and managers functioning within the Longhorn organization. Interviews with staff were supplemented with physical checks of operating, environmental and safety documentation systems to confirm the satisfactory execution of the management systems. The self-audit team also had the opportunity to visit the Cedar Valley pump station, Satsuma station, and the El Paso terminal and talk to supervisors and operators while at those facilities. The self-audit team also attended one of the regularly scheduled Monthly SIP meetings that was held at the Austin field office. All of the field related activities and interviews were conducted in March 2008.
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
Performance measures provide the means to measure progress in fulfillment of the established goals. Progress toward stated goals was reviewed by the audit team. Performance measures were compared against historical data and the desired outcomes. The performance measurement results are presented in Section 8 of this report. In addition, this review assessed the quality and effectiveness of the administration, communication, and documentation of the LPSIP program (LMP 3.5.12.3). 6.0 Self Audit Scope (LMP 3.5.12.3) -The LPSIP activities and program results for 2007 were reviewed to examine the processes used to identify and assess risks, evaluate risk control options, review justification for resource allocation, and monitor performance. This report specifically addresses the following five areas in the results section of this report: 1) Synopsis of the most important integrity issues being addressed on the Longhorn Pipeline System and the status of activities and programs used to manage these risks 2) Important insights, results, and lessons learned from the 2007 operating year 3) Insights from any new integrity management processes or technologies, or innovative applications of existing technologies 4) Performance measurement results 5) New integrity management programs or activities that will be conducted, or significant improvements to existing programs and activities resulting from the evaluation of the LPSIP 7.0 LPSIP Commitment Review (LMP 3.0) Longhorn expressly committed to proactively identify, analyze, and manage the inherent risks associated with the operation of the Longhorn system and its associated assets. Longhorn intended that commitment to be made to the public at large, the communities along the pipeline path, the environment, potentially impacted flora and fauna, regulatory agencies, Longhorn's employees, third party contractors and suppliers, and Longhorn's investors (LMP 3.1.1). LMP Section 3.2 identifies the use of formalized processes and programs which embrace and incorporate the elements of Pipeline Integrity Management in High Consequence Areas (HCA), Hazards and Operability Study (HAZOP), and Management of Change (MOC) processes. The integration of HCAs, HAZOP, and MOC into the LPSIP "Process Elements" (LMP Section 3.4) and the Detailed Program Descriptions (LMP Section 3.5) expanded Longhorn’s LPSIP to include proactive means to address the contributing factors of human error. These three sections of the LMP, Sections 3.2 through 3.4, were the focus of the audit. The Process Elements of the LPSIP are incorporated into the formal processes and procedures employed in Longhorn’s operations. Longhorn’s commitment to the installation, maintenance, and continuous improvement of its LPSIP is further supported through performance based metrics and critical self analysis. The requirements of the LMP are integral to these processes and procedures. To ensure that revisions of the specific processes do not remove or change LMP requirements and commitments, the audit team verified that they are controlled through a formal MOC process. The self-audit team tested the processes, documentation and recordkeeping of the Longhorn activities and found broad adherence with the LMP requirements. The audit team found staff from
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
the experienced operators in the field, their field supervisors on through to senior management have a good understanding of the reasons behind the LMP, the need to adhere to the commitments within the LMP itself as well as what those varied and actual commitments are. Further the team notes the existence of a formal program to turn the requirements or commitments as made in the LMP into actual work practices and programs, instructions, and the like. In regard to committing to improvements arising from the 2006 Self-Audit process, all recommendations from the 2006 Self-Audit were assigned to individuals within the Longhorn organization, and actions have been taken to address them. During the conduct of the self-audit, the audit team reviewed the following LPSIP elements, data and activities to support the completion of the performance measurement evaluation and assessment of effectiveness for inclusion in this report. 7.1 LPSIP Process Elements (LMP Sections 3.2.1, 3.4, and 3.5) The Longhorn Pipeline System Integrity Program consists of twelve specific “Process Elements. The Process Elements reflect actions that exceed those specified and required under various regulations and statutes, such as DOT’s pipeline safety regulations promulgated at Title 49 CFR Part 195. This forms the basis for the concept of “Compliance Plus in Longhorn’s operational philosophy. The LPSIP process elements serve as the foundation for the processes and activities intended to ensure asset integrity management and safe operation of the Longhorn Pipeline system. The following is a summary list of the twelve LPSIP process elements. 1. Corrosion Management Plan (CMP).This element includes cathodic protection system surveys and evaluations, pipe design, coating selection and application, inhibitor injection, and cathodic protection processes. 2. In-Line Inspection and Rehabilitation Program.This element includes the in-line inspection and rehabilitation processes for identifying and repairing conditions which present potential future integrity threats. 3. Key Risk Areas Identification and Assessment.This element addresses activities related to population density, environmental impact, land use and product characteristics, and the risk mitigation, analysis, management, and data assessment processes of the Relative Risk Assessment. 4. Damage Prevention Program.This element includes pipeline marking, surveillance, damage prevention and public education processes. 5. Encroachment Procedures.This element includes the processes Longhorn applies in the management of it rights as an easement owner to ensure a clear and unobstructed right-of-way. 6. Incident Investigation Program.This element includes the processes used to conduct incident investigations and to identify root causes of incidents and repairs. 7. Management of Change.This element covers the management of change processes applied when operational basis changes occur, including design review, risk assessment, team communication, and training protocols. 8. Depth of Cover Program.This element includes the processes used to identify and mitigate shallow or exposed pipe locations.
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Longhorn Partners Pipeline, L. P. 2007 Annual LPSIP Self-Audit Report May 20, 2008
9. Fatigue Analysis and Monitoring Program.This element covers the processes used to identify and mitigate the potential development of pressure-cycle-induced fatigue-related cracking, and evaluate the pipeline operations data supporting those processes. 10. Scenario Based Risk Mitigation Analysis.This element covers the processes used in the analysis of the pipeline operation, maintenance, integrity, surveillance, and public education results and the development of any preventative measures and system modifications recommended as a result of the analysis. 11. Incorrect Operations Mitigation.This element includes the processes used to proactively address the issues of human error in design, construction, maintenance and operation activities. 12. System Integrity Plan Scorecarding and Performance Metrics Plan.This element addresses the LPSIP scorecarding program performance monitoring processes. During the self-audit, each of the twelve process elements was reviewed to evaluate the extent to which the activities performed during 2007 were conducted in conformance with the LMP commitments, and that the results were incorporated into the ORA, the relative risk assessment model, and used to complete the annual third party damage prevention program assessment as required by the LPSIP for the activities that were carried out in 2007. During the 2007 self-audit, the team reviewed various tasks, actions, and processes within each of the twelve process elements to assess which of the commitments in the LMP were being implemented. In addition, based on the findings of the 2006 audit, the decision was taken to focus a part of our review and examine the activities within the following specific elements: − The Corrosion Management Plan, − In Line Inspection and Rehabilitation, − The Incident Investigation Program, − Management of Change, and − Incorrect Operations Mitigation. The twelve process elements of the LPSIP are incorporated into Magellan Midstream Partners (Magellan) System Integrity Plan (Magellan SIP), which was developed and is maintained by Longhorn’s operator, Magellan. As recommended in the 2006 LPSIP Self-Audit, Longhorn initiated a program in 2007 to review the Magellan SIP against the LMP and the LPSIP and identify any gaps that might exist between the two systems. This review has resulted in a series of changes or modifications that were made to the Magellan SIP. On January 1, 2008, Magellan issued its 2008 Magellan SIP. The self-audit team was provided the opportunity to review the 2008 Magellan SIP1 self-audit team identified various revisions to the 2007 version of the. The Magellan SIP, bringing these sections into closer alignment with the requirements of the LMP/LPSIP. The results of the audit team’s assessment of and observations on the twelve individual process elements comprising the Longhorn Pipeline System Integrity Program are provided in Section 8.1 of this Report. 1Magellan SIP was not within the scope of the Self-Audit.Compliance to the 2008 self-audit team reviewed the The 2008 Magellan SIP solely to understand the nature of changes that were approved by the element champions during the 2007 Magellan SIP reviews.
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